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f' <br />S. S. 5huey <br />Page 2 <br />shop with a regional market; 2) a specialty equipment repair and <br />machine shop that would support the local and region mining <br />industry; 3) a truck repair shop; 4) a mining supply store; or 5) <br />any combination of the above. In any case, this facility has a <br />competitive advantage compared to other facilities because it is <br />fully equipped and should not have a substantial debt service <br />obligation at the time it is converted to an industrial complex. <br />Somerset proposes to modify the reclamation plan based on an <br />industrial postmining land use. The area of the site that will be <br />reclaimed includes the west storage yards and the Elk Creek Coal <br />Stockpile area. This plan will preserve the central portion of the <br />site and the east storage yard to provide necessary land for <br />industrial use. The structures that will not be reclaimed include <br />the Elk Creek substation, the metal storage shed, the ambulance <br />garage, office building, shop warehouse building, sanitary <br />building, the roof bolt storage shed and the Elk Creek culvert. <br />This proposed land use change and resultant reclamation plan <br />revision affects the current mid-term review process mainly in the <br />area of reclamation bond requirement. Because a portion of the <br />site and seven structures will not be reclaimed, the Division's <br />current reclamation estimate will need to be revised. <br />Somerset proposes that the mid-term review process be finalized <br />prior to initiating the postmining land use change. Since the <br />estimated reclamation cost will be reduced because of the <br />postmining land use change, the decision on the reclamation bond <br />should also be delayed until the land use change is approved. <br />Please let me know if additional information will be required for <br />the Division to consider an industrial postmining land use for the <br />Elk Creek facilities and if the above approach to finalizing the <br />mid-term review is acceptable. <br />Sincerely, <br />Jim Stover, P.E. <br />Consulting Engineer <br />cc: W. A. Bear, Jr. <br />